Privacy Policy

This Privacy Policy explains how TopStep Partners (“we”, “us”, “our”) collects, uses, discloses, and safeguards your personal data when you interact with our website and affiliate network services. We are committed to protecting your privacy in accordance with the EU General Data Protection Regulation (GDPR) and other applicable global privacy laws.

TopStep Partners is the data controller responsible for the personal data collected through this site.

Our registered office is located at 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom. If you have any questions or concerns regarding this policy, you can contact our Data Protection Officer at affiliates@topsteppartners.com.

We may collect and process the following categories of personal data when you use our services or submit a partnership enquiry:

• Identity & Contact Data: Your full name, email address, and messaging handles (e.g., Telegram, Skype) provided via forms.
• Communication Data: The content of messages, inquiries, or feedback you send to us.
• Technical & Usage Data: IP addresses, browser types, device information, and interaction data collected via cookies and similar technologies.

We do not knowingly collect or process any special categories of personal data (e.g., information revealing racial or ethnic origin, political opinions, or health data). We may process limited technical data strictly to secure our forms.

Under the GDPR, we must have a lawful basis to process your personal data. We process your data for the following purposes:

• Consent (Art. 6(1)(a) GDPR): When you submit our contact form, subscribe to communications, or accept non-essential cookies. You may withdraw your consent at any time.
• Contractual Necessity (Art. 6(1)(b) GDPR): To enter into or perform our affiliate partnership agreement with you, manage your account, and process payouts.
• Legitimate Interests (Art. 6(1)(f) GDPR): To improve our website, ensure network security, prevent fraud, and manage business operations, provided these interests are not overridden by your privacy rights.
• Legal Obligation (Art. 6(1)(c) GDPR): To comply with applicable laws, including tax, anti-money laundering (AML), and regulatory requirements.

We do not sell your personal data. We may share your information with trusted third parties who assist us in operating our business, under strict data processing agreements:

• Service Providers: Providers of hosting, infrastructure, and analytics (e.g., Google Analytics). Transactional email is sent from our own mail infrastructure and is not passed to a third-party delivery service.
• Professional Advisors: Lawyers, auditors, and insurers who provide consultancy and legal services.
• Regulatory Authorities: Where compelled by law or to protect our legal rights, we may disclose data to law enforcement or governmental bodies.

Your personal data may be transferred to, and processed in, countries outside the European Economic Area (EEA). When we transfer your data internationally, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, such as:

• Transferring data to countries deemed to provide an adequate level of protection by the European Commission; or
• Utilising specific contracts approved by the European Commission (Standard Contractual Clauses) which give personal data the same protection it has in Europe.

We retain submitted contact details for up to 24 months for the purposes of evaluating and managing our affiliate partnership, after which they are securely deleted.

Where data is required for legal, tax, or regulatory compliance, we may retain it for longer periods as mandated by applicable law. Once the retention period expires, your data will be securely deleted or anonymised.

Depending on your location, including under the GDPR and various US state laws (e.g., CCPA/CPRA), you possess several rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of any inaccurate or incomplete data.
• Right to Erasure (“Right to be Forgotten”): Request the deletion of your personal data under certain conditions.
• Right to Restrict or Object: Limit or object to our processing of your data, particularly for direct marketing purposes.
• Right to Data Portability: Receive your data in a structured, commonly used format to transfer to another controller.
• Right to Withdraw Consent: Withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise these rights, please email us at affiliates@topsteppartners.com. We will respond within the statutory timeframe, usually one month.

You also have the right to lodge a complaint with a supervisory authority. For TopStep Partners, the primary authority is the Information Commissioner's Office (ICO) in the United Kingdom. You may also contact the supervisory authority in your habitual residence or place of work.

Our website uses cookies and similar technologies to enhance user experience and analyse traffic. By default, non-essential cookies are disabled until you explicitly opt-in via our cookie consent banner. You can manage your preferences or withdraw your consent at any time by adjusting your browser settings or clearing the topstep-consent entry in your local storage.

We implement robust technical and organisational measures to secure your personal data against accidental loss, unauthorised access, alteration, or disclosure. We limit access to your data to employees, agents, and contractors who have a strict business need to know and are subject to a duty of confidentiality.

We do not engage in automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you.

18+ Play Responsibly. Our website and affiliate programme are exclusively intended for individuals aged 18 and over. We do not knowingly collect personal data from minors. We are committed to responsible gambling. For support and guidance, visit https://www.begambleaware.org.

If you have any questions or require further information about our privacy practices, please contact TopStep Partners at:

affiliates@topsteppartners.com